HomeMy WebLinkAbout03-24-14 �
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Jonathan M.Crist,Esq. � � � �,�j n
1426 N,Third Street,Suite 200. � 'v � � "— 4
Harrisburg,PA 17102 � x r.. � ...{ c7
PH:(717)712-3131 r"` � �-y � P`r1 M
FX: (717)909-5925 �;', (n <<� '"� �
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In Re: Estate of RENA G. . IN THE COURT OF COMMON�LEA9� � m :
BURK, Deceased . OF CUMBERLAND COUNT� � � .�°,
. PENNSYLVANIA— ORPHANS'
. COURT DIVISION
. ESTATE NO. 21-13-0799
PETITION FOR DECREE TO COMPEL PERSONAL REPRESENTATIVE
TO FILE INVENTORY PURSUANT TO 20 Pa.C.S. §3301(c) AND TO FILE
ACCOUNTING PURSUANT TO 20 Pa.C.5. §3501.1
AND NOW comes Petitioner, COUNTRY MEADOWS ASSOCIATES, d/b/a
COUNTRY MEADOWS OF WEST SHORE, by and through its attorneys SB2 and
states:
1) Your Petitioner is COUNTRY MEADOWS ASSOCIATES, d/b/a
COUNTRY MEADOWS OF WEST SHORE with a business address of 830 Cherry
Drive, Hershey Pennsylvania 17033-2007.
2) The Decedent, RENA G. BURK, died on June 1, 2013 and June 29,
2013 Letters of Administration for the ESTATE OF RENA G. BURK, DECEASED
were granted by the Register of Wills of Cumberland County unto Kathy L. Hughes
of 740 Kise Mill Rd, York Haven, PA 17370 who is the niece of the Decedent.
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8) More than six months have passed since the last complete
advertisement of the grant of letters for the ESTATE OF RENA G. BURK
DECEASED and no accounting has been yet filed by the Administratrix Kathy L.
Hughes for the ESTATE OF RENA G. BURK DECEASED.
9) Pursuant to Cumberland County Rule 208.2(d) the undersigned
attorney has sought the concurrence of Craig Diehl, Esq attorney for the ESTATE
OF RENA G. BURK DECEASED with regard to the this Petition but which
concurrence was refused
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WHEREFORE, Petitioner, COUNTRY MEADOWS ASSOCIATES, d/b/a
COUNTRY MEADOWS OF WEST SHORE, requests this Honorable Court to issue
a Decree directing Kathy L. Hughes, as Administratrix of the Estate of ESTATE OF
RENA G. BURK DECEASED to file within thirty (30) days of the date of the service
of said Decree upon her:: (i) an Inventory for the Estate of ESTATE OF RENA G.
BURK, DECEASED and (ii) an Account of her Administration of the Estate of
ESTATE OF RENA G. BURK DECEASED, and to direct in accordance with 20 Pa
C. S § 3501.2 that there be annexed to said estate accounting a copy of the said
Kathy L. Hughes's account as plenary co-guardian of the Estate of RENA G. BURK
an incompetent person.
Respectfully Submitted,
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DATE: �� 2� ��� •�;...... ,' �/J`' ,
Jon�th n M. Crist, sq.
Atty 29936
1426 North 3rd Street, Suite 200
Harrisburg, PA. 17102
PH: (717) 712-3131
FX: (717) 909-5925
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In Re: Estate of RENA G. . IN THE COURT OF COMMON PLEAS
BURK, Deceased . OF CUMBERLAND COUNTY,
. PENNSYLVANIA - ORPHANS
. COURT DIVISION
. ESTATE NO. 21-13-0799
V E R I F I C A T I O N
I Vincent J. Mizak hereby state that I am the Senior Vice President of
Country Meadows Retirement Communities and authorized to take this verification
on its behal£ The attached Petition is based upon information which has been
furnished to counsel and information which has been gathered by counsel in
preparation of this matter. The language of the Petition is that of counsel and not
of ine. I have read the Petition and to the extent that the Petition is based upon
information which has been given to counsel, it is true and correct to the best of my
knowledge, information and belief. To the extent that the content of the Petition is
that of counsel, I have relied upon counsel in making this verification.
I hereby acknowledge that the facts set forth in the aforesaid Petition are
made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to
authorities.
DATE: � 1'� zp t�
VINCE T . MIZAK
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving the foregoing Petition For Decree
To Compel Personal Representative To File Inuentory Pursuant to 20 Pa.C.S.
�3301(c) and to File Accounting Pursuant to 20 Pa.C.S. �3501.1 upon the persons
and in the manner indicated below which service satisfies the requirements of
Pa.R.A.P. 1514:
Seruice bvi certified first class mail addressed as follows:
Craig A. Diehl
Law Offices of Craig A. Diehl
3464 Trindle Road
Camp Hill, PA 17011
and
Service by Certified first class mail addressed as follows:
Kathy L. Hughes
740 Kise Mill Rd
York Haven, PA 17370
Dated: �)a� �y'
Tonya D ugherty, Par gal
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